On March 16, 1999, a Consent Decree was entered in Federal District
Court, District of Connecticut, resolving a Complaint filed against
Pfizer Inc., located in Groton, Connecticut. The Complaint alleged
violations of the Resource Conservation and Recovery Act (RCRA),
the Clean Water Act and the Emergency Planning and Community Right-to-Know
Act. In conjunction with the settlement, Region I issued to Pfizer
regulatory interpretations of certain RCRA requirements
in order to facilitate future compliance at Pfizer's Groton facility.
The specific requirements for which regulatory interpretations
were issued are: satellite accumulation, movement of hazardous
wastes to storage areas; stacking and configuration of drums to
allow for proper inspection; inspection logs; and container labeling
in laboratories. Some of the interpretations, such as those for
the inspection log and container labeling requirements, are based
on federally-authorized Connecticut hazardous waste regulations
which are more stringent than the federal requirements. Moreover,
the satellite accumulation interpretation has been geared toward
specific factual scenarios that existed at the Pfizer plant
in Groton, Connecticut. Nevertheless, the interpretations may
prove useful to the regulated community in general throughout
New England. The interpretations are set forth on the left. If
you have any questions regarding these interpretations, please
contact Richard Piligian at (617) 918-1757, or Andrea Simpson at
(617) 918-1738.